Treasury’s final rule implementing its outbound investment regime went into effect on January 2, 2025. The final rule implemented Executive Order (E.O.) 14105 of August 9, 2023, which declared a national emergency to address...more
On January 13, 2025, BIS issued an interim rule amending the EAR to, among other things, impose a new control on certain advanced AI model weights for certain advanced closed-weight dual-use AI models, and revise controls on...more
Background -
On December 2, 2024, BIS announced two new rules under the EAR targeting the PRC’s ability to produce “advanced-node” semiconductors, including advanced-node integrated circuits (ICs), which can be used in...more
New OFAC Guidance on Statute of Limitations -
On July 22, 2024, the Office of Foreign Assets Control (OFAC) published new guidance addressing how it intends to apply a recent change in the statute of limitations for...more
On June 12, 2024, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced several significant additional export control restrictions and related actions against Russia as a response to continued...more
6/26/2024
/ Belarus ,
Belarus Sanctions ,
Bureau of Industry and Security (BIS) ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Foreign Policy ,
General Licenses ,
Office of Foreign Assets Control (OFAC) ,
Russia ,
SDN List
On April 25, 2024, the Department of Commerce’s Bureau of Industry and Security (BIS) announced the issuance of a final rule that amends the Russian and Belarus Sanctions under the Export Administration Regulations (EAR) to...more
As the 49th Group of Seven (G7) Summit gets underway in Japan, the United States, in coordination with several other G7 members, marked the occasion to announce sweeping new sanctions and export controls aimed at “further...more
On February 24, 2023, the White House marked the one-year anniversary of the Russian invasion of Ukraine by announcing a sweeping package of new sanctions, export controls and tariffs aimed at “holding Russia accountable for...more
On February 16, 2023, the U.S. Department of Justice (DOJ) and the U.S. Department of Commerce announced the creation of the “Disruptive Technology Strike Force” — a multi-agency, multi-geographical effort to ratchet up the...more
Summary of Key Points:
Although this rule is aimed at the semiconductor and supercomputer industries, it will have a much broader effect on U.S. and ex-U.S. manufacturing, including even certain EAR99 goods manufactured...more
Seven months into Russia’s invasion of Ukraine, the United States continues to expand and develop its Russia sanctions program. Most recently, the U.S. Department of the Treasury’s Office of Foreign Assets Control (OFAC)...more
In an anticipated move, the Biden administration escalated its forced labor enforcement efforts on June 24 by announcing the issuance of a new withhold/release order (WRO) that blocks the import of certain polysilicon-based...more
It may be time to reevaluate your company’s approach to “deemed exports” and the hiring of foreign nationals, based on the recent changes to the country designations of Myanmar/Burma, Russia and Hong Kong, as well as the...more
The Biden administration continues to utilize United States trade sanctions and export controls as a key tool in its efforts to put pressure on China, Myanmar/Burma and Russia. Since our last update, actions by the U.S....more
4/30/2021
/ Biden Administration ,
Bureau of Industry and Security (BIS) ,
Commerce Control List ,
Directorate of Defense Trade Controls (DDTC) ,
ECCNs ,
Economic Sanctions ,
Export Administration Regulations (EAR) ,
Export Controls ,
Office of Foreign Assets Control (OFAC) ,
Popular ,
SDN List
In its first 50 days, the Biden administration has been busy utilizing sanctions and export controls to support its foreign policy priorities of human rights, multilateralism and support for democratic regimes. The U.S....more
On January 13, 2021, President Trump amended the November 12, 2020, Executive Order (EO) 13959 providing greater clarity to the scope of the EO’s ban on trading and investing in certain designated publicly traded securities...more
On December 21, 2020, the Department of Commerce’s Bureau of Industry and Security (BIS) added 102 Chinese and Russian companies to a new restricted “Military End User” (MEU) list in the U.S. Export Administration Regulations...more
As previously discussed, on April 28, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) announced significant changes to the Export Administration Regulations (EAR) to further restrict transactions...more
7/1/2020
/ Bureau of Industry and Security (BIS) ,
China ,
Commerce Control List ,
Electronic Export Information (EEI) ,
Export Administration Regulations (EAR) ,
Export Controls ,
Exports ,
Military End Use ,
Russia ,
U.S. Commerce Department ,
Venezuela
On June 15, 2020, the U.S. Department of Commerce revised its existing export controls on Chinese telecoms company Huawei to permit limited sharing of some export-controlled technology with Huawei in the context of...more
On May 22, 2020, the U.S. Department of Commerce’s Bureau of Industry and Security (BIS) added 33 Chinese entities and research institutions to its prohibited “Entity List.” This latest action illustrates the U.S....more
On May 15, 2020, the U.S. Commerce Department’s Bureau of Industry and Security (BIS) announced that it was amending the U.S. Export Administration Regulations (EAR) to further restrict the ability of Chinese telecom and IT...more